ML17285A929

Requests Temporary Relief from Tech Spec Surveillance Requirement Applicable to Emergency Diesel Generator Fuel Oil Accelerated Stability Testing.Util Will Provide for Monthly Sampling from Discharge of Running Fuel Oil Pump

ML17285A929
Person / Time
Site:	Columbia
Issue date:	01/03/1990
From:	Powers C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-90-003, GO2-90-3, NUDOCS 9001160172
Download: ML17285A929 (7)

Text

ACCELERATED UTION DEMON TION. SYPH REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) ~

ACCESSION NBR: 9001160172 DOC. DATE: 90/01/03 NOTARIZED: NO DOCKET'8 FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION POWERS,C.M. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) R

SUBJECT:

Requests temporary relief from TS Surveillance Requirement 4.8.1.1.2.d.2.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE: D TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA PD5 PD SAMWORTH,R D INTERNAL: ACRS NRR/DET/ECMB 9H NRR/DOEA/OTSB11 NRR/DST 8E2 NRR/DST/SELB 8D NRR/DST/SICB 7E NRR/DST/SRXB 8E NUDOCS-ABSTRACT OC LFMB OGC/HDS2 G E RES/DSIR/EIB EXTERNAL: LPDR NRC PDR NSIC R

D A

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP, US TO REDUCE WASTE! CONTACT THE. DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED: LTTR 27 ENCL ~4 pi

)

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 January 3, 1990 G02-90-003 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2, OPERATING LICENSE NPF-21 RE(UEST FOR TEMPORARY RELIEF FROM TECHNICAL SPECIFICATION SURVEILLANCE RE(UIREMENT 4.8.1.1.2.d.2 The purpose of this letter is to request a one time relief from the Technical Specification surveillance requirement applicable to emergency diesel generator fuel oil accelerated stability testing (4.8. 1. l.d.2).

The subject Technical Specification section requires that the fuel oil impurity level be less than 2 mg of insolubles per 100 ml when tested in accordance with ASTM D2274-70.

On January 2, 1990 the Supply System was notified of results from quarterly samples taken on December 27, 1989 that indicated impurity levels were:

2.0 mg/100 ml - Tank 1A (Division A diesel) 5.6 mg/100 ml - Tank 1B (Division B diesel) 2.6 mg/100 ml - Tank 2 (HPCS diesel)

The Supply System responded to this information by contacting two outside consultants who indicated that it would be unusual to experience a step change in the impurity level. Previous sample results were in the range of 0.6 to 1.0 mg/100 ml.

9'001160172 900103 PDR ADOCK 05000397 P PDC

~ 'P

.Page Two RE(UEST FOR TEMPORARY RELIEF, FROM TECHNICAL SPECIFICATION RE(UIREMENT 4.8.1.1.2.d.2 'URVEILLANCE It was decided to request that the contract laboratory repeat the tests and on January 3, 1990 the results of the second test were provided as:

1.7 mg/100 ml - Tank 1A 4.7 mg/100 ml - Tank 1B 2.4 mg/100 ml - Tank 2 With these two sets of results we concluded that the l'aboratory testing method was probably acceptable but as the samples for the second tests were the same as for the first we could not confirm the sampling method.

To obtain data more indicative of the current condition of the fuel oil quality, on January 3, a test was performed to the requirements of ASTH D2276-78, Method A. The use of ASTH D2276-78 for determining fuel oil quality with respect to stability and storage has been approved for Limerick-1/2, Wolf Creek, and the McGuire-1/2 plants. Where ASTM D2276-78 is utilized no requirement to meet ASTH D2274-70 is imposed.

The above test was performed by the contractor with fuel of the original sample.

These samples had been obtained by a fuel thief from the bottom of the bulk fuel oil storage tanks per ASTH D270-1975. The results of these tests were:

4.3 mg/liter - Tank 1A 9.8 mg/liter - Tank 1B 7.9 mg/liter - Tank 2 The Supply System believes the acceptable test results to ASTH D2276-78 provide an adequate bases for the NRC to grant temporary relief from the subject Technical Specification requirement as the ASTH D2276-78 test provides results that are more indicative of the current condition of the fuel oil quality than the ASTH D2274 accelerated stability test. The ASTH D2274 test is performed under an extreme testing environment and the results are only indicative of long term storage stability.

The fuel oil analysis includes all the diesel engine manufacturer's fuel oil testing recommendations. All these parameters fell within the recommended limits. The diesel manufacturer has not established a recommended limit for a ASTH D2274-70 test. A preliminary Supply System analysis of Tank 1B, per ASTH D2276 indicated an insoluble content of 1.8 mg/liter

II

. Page Three REQUEST FOR'EMPORARY RELIEF FROM TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 4.8.1.1.2.d.2 The three diesels are available for service and operable in all respects with the one exception of the subject insolubility limit. As stated above, this includes satisfying all other fuel quality requirements including those required by the Technical Specifications, the diesel manufacturer and ASTH 2276-78. In addition we do not believe that exceeding the ASTH D2274 insolubility limit is an indication that the diesels will not perform as required.

With the approval of the requested one time relief of the Technical Specification surveillance requirement, the Supply System will provide for monthly sampling from the discharge of the running fuel oil transfer pump and testing in accordance with ASTH D2276 Method A. Action will be taken based on compliance with an acceptance criterion of <10.0 mg/liter.

During this period the Supply System will initiate a Technical Specification change to replace the ASTM D2274 test with the ASTH D2276 Method A test.

Very truly yours,

. M. Powers WNP-2 Plant Manager AGH/bk cc: JB Martin - NRC RV NS Reynolds - BCPER RB Samworth - NRC DL Williams - BPA/399 NRC Site Inspector - 901A

r